ID: nht93-8.35

DATE: November 30, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ray Paradis -- Manufacturing Manager, Dakota Mfg. Co., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/16/93 from John Womack to Ray Paradis

TEXT:

This responds to your FAX of November 18, 1993, requesting a clarification of our letter of November 16 as it applies to the rear of the trailers shown in items #5 and #7 which accompanied your letter of August 31, 1993.

As we advised you with respect to rear markings, Standard No. 108 requires a horizontal strip of retroreflective sheeting across the full width of the trailer. With respect to the trailer shown in #7, retroreflective tape can be applied across the full width of the "approach ramp" to meet the requirements since the ramp will be in the down position when the trailer is moving.

As we further advised you, paragraph S5.7.1.3(b) anticipates that the length of the color segments may have to be modified to facilitate using material near rear lamps. In the worst cases of trailers with rear surfaces no wider than the minimum required for lamps. breaks in the rear treatment are unavoidable to clear the lamps. But NHTSA expects the manufacturer to minimize the breaks by using red material adjacent to red lamps. With respect to #5, we recommend applying red/white conspicuity treatment on either side of the identification lamps, with red material used in the remaining outboard areas.

I hope that this answers your questions.

ID: 9151

Mr. Ray Paradis
Manufacturing Manager
Dakota Mfg. Co., Inc.
Box 1188
Mitchell, SD 57301

Dear Mr. Paradis:

This responds to your FAX of November 18, 1993, requesting a clarification of our letter of November 16 as it applies to the rear of the trailers shown in items #5 and #7 which accompanied your letter of August 31, 1993.

As we advised you with respect to rear markings, Standard No. 108 requires a horizontal strip of retroreflective sheeting across the full width of the trailer. With respect to the trailer shown in #7, retroreflective tape can be applied across the full width of the "approach ramp" to meet the requirements since the ramp will be in the down position when the trailer is moving.

As we further advised you, paragraph S5.7.1.3(b) anticipates that the length of the color segments may have to be modified to facilitate using material near rear lamps. In the worst cases of trailers with rear surfaces no wider than the minimum required for lamps, breaks in the rear treatment are unavoidable to clear the lamps. But NHTSA expects the manufacturer to minimize the breaks by using red material adjacent to red lamps. With respect to #5, we recommend applying red/white conspicuity treatment on either side of the identification lamps, with red material used in the remaining outboard areas.

I hope that this answers your questions.

Sincerely

John Womack Acting Chief Counsel

ref:108 d:11/16/93

ID: nht74-4.29

DATE: 06/19/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Busby, Rivkin, Sherman, Levy, and Rehm

COPYEE: DYSON; DUGOFF; CARTER

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 10, 1974, in which you asked for our interpretation of the preemption provisions of the National Traffic and Motor Vehicle Safety Act (sec. 103(d)) with respect to the Pennsylvania position on brake hose. A letter that you enclosed from the Pennsylvania Department of Transportation advised a manufacturer's representative that "Pennsylvania will continue to approve brake hoses under the SAK Standards for air, hydraulic and vacuum hose," and that the State "will continue to require the hose be identified in the same manner as our present regulations," with the Federally-required labeling placed on "a separate line" from the State's labeling.

Section 103(d) of the Act, 43 U.S.C. 1392(d), plainly prohibits any State from establishing or continuing in effect a safety standard applicable to an item of motor vehicle equipment, where there is an applicable Federal standard, unless the State standard is "identical to the Federal standard." This preemption provision takes effect wherever a Federal standard is applicable to the same aspect of performance as the State standard. When the new Federal standard on brake hoses comes into effect, with its testing and labeling requirements, any differing State standards, as Pennsylvania's appear to be, will be preempted and void.

ID: aiam1186

Dear Mr. Kulik: This is in reply to your letter of May 18, 1973, concerning the metho of testing the sensitivity of seat sensors under sections S7.3 and S7.4 of Federal Motor Vehicle Safety Standard No. 208.; The relevant characteristics of the 'person' referred to in thes sections are found in the weight and dimension table of Section S7.1.3 of the standard. Our testing laboratory will, in all likelihood, be using test dummies purchased from the various commercial dummy manufacturers, whose weights and dimensions conform to S7.1.3 of the standard. Human volunteers could be used, but the dimensional controls are difficult to maintain and we do not regard liver (sic) persons as a practical means of testing sensors under the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht78-1.6

DATE: 12/15/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Bud Shuster - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Honorable Bud Shuster House of Representatives Washington, D.C. 20515

Dear Mr. Shuster:

This responds to your inquiry dated November 29, 1978, on behalf of one of your constituents, Mr. C. Stake, requesting information about Federal safety standards concerning door locks on automobiles. Specifically, Mr. Stake is concerned that the doors on his 1977 Mercury Monarch can be unlocked by a child from the inside by lifting the door handle.

I am enclosing a copy of Safety Standard No. 206 (49 CFR 572.206), which specifies performance requirements for side door locks and side door retention components to minimize the likelihood of occupants being thrown from the vehicle as a result of impact. That standard specifies that each door on a passenger car shall be equipped with a locking mechanism with an operating means in the interior of the vehicle. Paragraph S4.1.3.1 of the standard specifies that when the locking mechanism on a side front door is engaged, the outside door handle or other outside latch release control shall be inoperative. For side rear doors, however, paragraph S4.1.3.2 requires both the outside and inside door handles to be inoperative when the locking mechanism is engaged.

This latter requirement was specifically included in the standard to address Mr. Stake's concern, that is, to prevent children from unlocking rear doors by means of the door handle. The design restriction was limited to rear doors on the basis that the danger arises primarily with unattended children sitting in the rear seat. A child sitting in the front seat is likely under the watchful eye of the driver. Further, there is the consideration that in emergency situations the driver may need to unlock his front door as easily and quickly as possible.

Since the Standard No. 206 requirements have been in effect for some time, we assume that the situation Mr. Stake describes is true only of the front doors of his Mercury Monarch. As noted above, however, there are competing safety considerations involved with door locks on front side doors.

Please contact our office if your constituent has any further questions concerning this matter, or have him contact us directly.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Enclosure

DATE November 29, 1978

FROM: BUD SHUSTER, M. C.

Room 1112 Longworth Building Washington, D. C. 20515

TO: Department of Transportation Congressional Laison Office 400 Seventh Street, S.W.

Washington, D.C. 20590

NAME OF SUBJECT Mr. Clair Stake

SS OR OTHER CLAIM #

ADDRESS Box 115

Spring Run, Pennsylvania 17262

PROBLEM:

Mr. Stake has contacted me concerning car door lock safety standards. He owns a 1977 Mercury Monarch. When the door is locked (by pushing the button on the inside of the door) he finds that his young child can still open the door by pulling on the door handle.

This concernins him because be beleives that there should be safety standards which should require the door handle to be immobile until the lock button is pulled up.

Will you please send me any information on door lock standards? Thank you for your time and cooperation in this matter.

ID: aiam1234

Dear Ms. Black: This is in reply to your letter or July 18, 1973, regarding th applicability of Standard No. 302, 'Flammability of Interior Materials,' to a temporary sunvisor sleeve British Leyland plans for each of its 1974 model cars, to inform occupants about the seat belt interlock system.; The applicability of Standard No. 302 depends on whether th instruction sleeve is attached in such a way as to appear as a permanent part of the sunvisor or some other interior component covered by the standard. If the instruction sleeve is easily removable, is obviously not part of the sunvisor, and is clearly intended to be removed by the owner, we would not consider the sunvisor sleeve to be subject to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1217

Dear Mr. Gill: This is in reply to your letter of July 6, 1973, regarding th applicability of Standard No. 302 to a label that Honda wants to place on the driver's side sun visor to inform occupants about the seat belt interlock system.; The applicability of the standard depends on whether the label i attached in such a way as to form a permanent part of the sun visor. You state that Honda's label is 'easily removable and obviously not part of the sun visor.' If the label meets these criteria, we would not consider it to be a part of the visor. It would therefore not be subject to Standard No. 302.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht92-7.11

DATE: May 8, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: J.W. Lawrence -- Volvo GM Heavy Truck Corporation

TITLE: None

ATTACHMT: Attached to letter dated 10/25/91 from J.W. Lawrence to NHTSA Administrator (OCC 6634)

TEXT:

This responds to your letter of October 25, 1991 requesting information on whether metric sizes and threads for attachment bolts would be considered "equivalent hardware for the requirements of S4.1(f) of Standard No. 209, Seat Belt Assemblies. In general, it is permissible to use metric hardware for the installation of safety belts. However, as explained below, it is unclear whether the metric fastener M12, as described in your follow-up letter of December 13, 1991, is equivalent to the attachment hardware specified in Standard No. 209.

The Department of Transportation is implementing the policy of using metric dimensions, in addition to American Standard dimensions, in our regulations. Currently, FMVSS No. 209 "Seat Belt Assemblies," requires the safety belt anchorage bolt to be

"7/16-20 UNF-2A or 1/2-13 UNC-2A attachment bolts or equivalent hardware" (S4.1.(f)).

The SIZE of the bolt specified in your letter is equivalent to the safety belt anchorage bolt specified in Standard No. 209. Since the M12 nut is approximately halfway between a 7/16 and a 1/2 inch bolt, it is clear that the size would fulfill the requirement of the standard. However, it is not clear from the information provided, whether the class of thread fit of the metric bolt is comparable to the requirements of the standard. The standard does specify a Class 2 bolt. A Class 2 thread provides clearance under all conditions and allows external threads to be plated with no resultant assembly difficulties. This is the most common commercial grade fit. Therefore, if the bolt thread fit is equivalent, we would consider this metric bolt to be equivalent hardware to the bolt specified in Standard No. 209.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: 1983-1.31

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/83 EST

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA

TO: HOUTAN MOSTAGHIM -- VICE PRESIDENT, PAN UNITED INC.

TITLE: NOA-30

ATTACHMT: MEMO DATED 3-4-83, FROM HOUTAN MOSTAGHIM, TO NHTSA, REF: PUI 109/383, TITLED DOG CLIP

TEXT: This responds to your letter of March 4, 1983, asking whether there are any Federal regulations applicable to an accessory component used to secure pets to vehicle seat belts. The component latches into the seat belt buckle and is then attached to the pet's collar or leash. Your company intends to import these accessories.

There are no Federal motor vehicle safety standards or regulations applicable to the product you describe. Therefore, as far as this agency is concerned, there are no responsibilities you must meet prior to importing this item (i.e., there are no testing or licensing requirements). You should, however, contact State authorities to determine if they have any licensing requirements or regulations that would be applicable to the sale of such a device.

You will have to contact private counsel to determine the product liability implications and insurance needs of your enterprise.

Thank you for your inquiry.

ID: nht92-3.50

DATE: September 17, 1992

FROM: John D. Dingell -- Chairman, U.S. House of Representatives, Committee on Energy and Commerce

TO: Marion C. Blakey -- Administrator, NHTSA

COPYEE: Aaron Gordon

ATTACHMT: Attached to letter dated 11/9/92 from Marion C. Blakey to John D. Dingell (A40; Std. 222)

TEXT:

Enclosed is a letter I received from Mr. Aaron Gordon about seat belts for school buses. The writer refers to H.R. 896. I request your comments, including comments on the bill. Please provide a copy of your reply to Mr. Gordon.

Enclosure Letter dated February, 1992 from Aaron Gordon to John Dingell:

Dear Honorable John Dingell,

My name is Aaron Gordon. I'm a fourth grader at Leewood Elem. School. For the last two years I have been researching seat belts on school buses. I designed a double shoulder harness that the Committee of Transportation of Florida has appropriated $25,000 to research my design.

Congressman Andy Jacobs Jr., from Indiana has writen a bill (H.R. 896) that I support. I know of your (words illegible) of the safety of children. I'm requesting the opportunity to speak on this issue, before Congress or (word illegible) committee (words illegible) public hearing is held on this bill.

Please let me know when this will take place.